CBD cosmetics: what a label is allowed to promise
A CBD cosmetic may state what it contains and the cosmetic functions it can prove, nothing beyond that. Regulation (EU) No 655/2013 tests every claim against six common criteria, truthfulness and evidential support among them. Once a sentence credits the product with an effect on a disease, the product leaves the cosmetics regime.
Key takeaways
- Check "With CBD" against the ingredient list: it states a composition.
- A function such as "moisturises" needs an evidence file covering the finished product; data on the molecule alone falls short.
- No cosmetic may claim an effect on a disease or on a bodily function.
- SCCS opinion SCCS/1685/25 of 26 March 2026 judges cannabidiol safe up to 0.19% on the skin. It addresses safety only and says nothing about efficacy.
What the law calls a claim
Any statement that attributes a characteristic or a function to the product is a claim. The principle comes from Article 20 of Regulation (EC) No 1223/2009: texts, names, trade marks and pictures must not suggest characteristics or functions the product does not have.
Regulation (EU) No 655/2013, adopted on 10 July 2013 and applicable since 11 July 2013, sets out the criteria. Under its Article 1 it applies to texts, names, trade marks, pictures and signs, explicit or implicit, in labelling, when products are made available and in advertising, on any medium. An online shop's product page, a social media visual and the product's trade name all fall within it.
With hemp, one distinction settles many cases. "With CBD" or "with hemp seed oil" states a composition that you can check on the INCI list. The function claim is whatever property is then attached to that ingredient. Composition is covered in our article on allergens, fragrance and the label of a CBD cosmetic; this article deals with the promise.
The six common criteria, read for a product page
| Criterion | What it requires | What it means for a product page |
|---|---|---|
| Legal compliance | No benefit presented that is only compliance with the law | Do not sell a "legal" THC level as a quality |
| Truthfulness | No false information | Do not give the finished product an ingredient's properties without proof |
| Evidential support | Adequate and verifiable evidence | Keep a file: test, consumer study, published data |
| Honesty | Presentation does not go beyond the evidence | State the real scope of the test, not an extrapolation |
| Fairness | No denigration of competitors or of authorised ingredients | Do not suggest that a lawful ingredient is dangerous |
| Informed decision-making | Clear information for the average user | Write for a non-specialist, without ambiguity |
The first criterion often catches brands out. The regulation's annex bans presenting mere compliance with a legal requirement as a benefit. A balm that advertises its Δ⁹-THC below 0.30% turns a condition of sale into a selling point.
Brands differ most on the third criterion. A user review falls short, and a study on isolated cannabidiol says nothing about a finished balm on the skin. The evidence has to cover the claim itself, under the stated conditions of use.
Six wordings put through the filter
| Wording | Status | Criterion involved |
|---|---|---|
| "With hemp seed oil" | Acceptable if the ingredient is on the INCI list | Truthfulness |
| "Moisturises the skin" | Acceptable if a test supports it | Evidential support |
| "Dermatologically tested" | Acceptable if the test exists | Truthfulness, evidential support |
| "THC-free" | Best avoided | Truthfulness: traces are common; compliance: obeying the law is not a benefit |
| "Free from chemicals" | Not acceptable | Truthfulness: all matter is chemical |
| "Works on eczema" | Not acceptable | Outside the scope of cosmetics |
The DGCCRF, France's consumer protection authority, has set out its position on "free from" claims. Its guidance on "free from" claims in cosmetics rejects three kinds of wording: "free from" followed by a substance already banned, unverifiable statements such as "free from endocrine disruptors", and those that denigrate an authorised ingredient, such as "paraben-free". A manufacturer may write "hypoallergenic" if it can prove it, and useful information such as "alcohol-free" is tolerated.
For a product page limited to checkable facts (composition, dilution, storage), see our guide to CBD massage oil, INCI, dilution and storage.
The line with medicines
Regulation (EC) No 1223/2009 defines a cosmetic by what it is for. It is a preparation placed in contact with the external parts of the body, the teeth or the mucous membranes of the mouth. Its purpose is to clean, perfume, change the appearance of, protect, keep in good condition or correct body odours.
Two consequences follow. Article 2(2) excludes any product meant to be ingested, inhaled, injected or implanted. A statement crediting the product with an effect on a disease moves it towards medicine status, which requires a marketing authorisation. Epidyolex, the only cannabidiol medicine authorised in France, took that route. As the French government's drug policy site points out, CBD products may not make therapeutic claims, under penalty of criminal sanctions.
The market explains why the rule bears repeating. Published in December 2023, a study by French addiction-monitoring centres, funded by MILDECA analysed 248 CBD products bought in France, 2 of them cosmetic creams. Of these, 46% had no composition labelling, and 30 exceeded the THC limit at 0.4 to 1.2%. Many of the 33 online shops examined credited CBD with effects on serious diseases. The consumer-law side is covered in our article on the rules for advertising CBD.
What opinion SCCS/1685/25 adds, and what it does not allow
The EU Scientific Committee on Consumer Safety (SCCS) gave a preliminary opinion on 30 October 2025. Its final opinion on cannabidiol in cosmetics was adopted on 26 March 2026 and published on 24 April 2026. The committee judges cannabidiol safe up to 0.19% in products applied to the skin or in the mouth, alone or combined. It puts the safe level of THC, present as an impurity, at 0.00025%.
Products that expose the lungs through inhalation are excluded, and only pure cannabidiol is covered. The committee itself remarks on how little data it received. The opinion assesses a risk: it validates no property and takes the place of no evidence. No brand can write "approved by Europe" on the strength of it. Our guide to topical CBD cosmetics offers a reading grid for judging a cream or a balm.
How Phytogrammes writes its oil product pages
Checked on 23 September 2026, the CBD oils page of our catalogue presents its products for external application under Regulation (EC) No 1223/2009. The products are neither foods nor food supplements, and the page claims no property for them. Depending on the product, cannabidiol content runs from 5 to 20%.
A product page then sticks to what can be checked: composition, concentration, batch number and Δ⁹-THC below 0.30%. Our guide to the CBD certificate of analysis shows what such a certificate should contain, and compliance questions are collected in our FAQ.
Frequently asked questions
It is any text, name, trade mark, picture or sign, explicit or implicit, that attributes a characteristic or function to the product. Regulation (EU) No 655/2013 applies on the label, when the product is made available and in advertising. A page in an online shop counts as much as a bottle.
Yes, provided the ingredient is present and declared in the ingredient list, since this states a composition. Any property attached to it becomes a function claim, to be backed by evidence on the finished product.
No. Effects on pain, a disease or a bodily function are the domain of medicines. Such a statement makes a cosmetic non-compliant, and French law bans any therapeutic claim for CBD products.
No. Under Article 2 of Regulation (EC) No 1223/2009, a product meant to be ingested, inhaled, injected or implanted is not a cosmetic.
Written by the Phytogrammes team
Each journal article draws on cited primary sources: ANSM, EFSA, EUR-Lex and peer-reviewed publications. Product profiles are distinguished from documented laboratory results. Our approach.
Article published on . CBD is not a medicine.